received oct 01 2qw...as to him, but that since they were reported there was no issue as to...

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON DC

IN THE MATTER OF FINRAS NATIONAL ADJUDICATORY

COUNCILS DECISION PLAINTIFF

vs

ALLEN HOLEMAN RESPONDENT

COMPLAINT NO 2014043001601

DATED MAY 21 2018

SEC ADMINISTRATIVE PROCEEDING

FILE NO 3-18546

RESPONDENTS ANSWER TO FINRAS BRIEF IN

OPPOSITION TO THE APPELLANTS APPLICATION FOR

REVIEW OF DISCIPLINARY ACTION TAKEN BY FINRA

BEFORE THE SECURITIES AND EXCHANGE COMMISSION

September 28 2018

RECEIVED

OCT 01 2QW

OFFICE OFTHESECRETARY

TABLE OF CONTENTS

I RESPONDENTS ANSWER TO FINRA BRIEF IN OPPOSITION TO THE APPELLANTS APPLICATION FOR REVIEW OF DISCIPLINARY ACTION TAKEN BY FINRA 1

II F O RM U 4 FI LIN GS 4 5

III THE ANNUAL COMPLIANCE QUESTIONNAIRE S

IV ENFORCEMENTS INACCURATE AND MISLEADING ST A TE M E NTS 5 6 7

V ARGUMENTS 789

VI CONCLUSION 910

TABLE OF AUTHORITIES

Case

Department of Enforcement v Vincent 78

Disciplinary Proceeding No 2013036653301

Other Authorities

Respondents Opening Brief in Support of the Application for Review

of Disciplinary Action Taken by FINRA filed with the SEC August 15

2018 125 8

Certified Record index -CX-24 5

FINRAs Opposition to Application for Review dated September 17

2018 679

Hearing Transcript dated January 19

2017 610

ii

16

17

20

2 BEFORE THE

3 UNITED STATES SECURITIES AND EXCHANGE COMMISSION

4 WASHINGTON DC

5

6

7

IN THE MATTER OF FINRAS NATIONAL ADJUDICATORY COUNCILS DECISION

8 PLAINTIFF

9 vs

10

11

ALLEN HOLEMAN

SYOSSET NY

SEC ADMINISTRATIVE PROCEEDING FILE NO 3-18546

12 RESPONDENT

13 COMPLAINT NO 2014043001601

14 DATED MAY212018

15

RESPONDENTS ANSWER TO FINRAS BRIEF IN OPPOSITION TO THE APPELLANTS

APPLICATION FOR REVIEW OF DISCIPLINARY ACTION TAKEN BY FINRA 18

I INTRODUCTION19

Allen Holeman (Holeman) appeals to the SEC the May 21 2018 Decision of the

21

22

23

National Adjudicatory Council (the NAC) seeking to vacate the NAC Hearing Panels finding

and sanctions including the fine suspension willful determination and associated costs 1

24

25

26

27

28

1 See Respondents Opening Brief in Support of the Applicationor Review of Disciplinary Action Taken by FIN RA filed with the SEC August 15 2018

5

10

15

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25

Holeman repeats and incorporates by reference the Principal Considerations Arguments

2 and Conclusion in Respondents Opening Brief in Support of the Application for Review of

3

Disciplinary Action Taken by FINRA filed August 15 2018 with the SEC2 The record does not 4

(emphasis added) demonstrate that Holeman allegedly failed to timely amend his Form U4 to

disclose three federal tax liens The record does not (emphasis added) support the alleged findin 6

7 that Holeman was on notice of the federal tax liens at or about the time of their filing in 2009

8 Contrary to FINRA Enforcements (Enforcement) claim that the contention that Holemans

9

position he never received notice nor was he aware of any of the three federal tax

liens stands in direct conflict with a position Holeman held earlier in the investigative process 11

12 that the Internal Revenue Service (IRS) informed him of the liens is patently false and

13 misleading Holeman has held from the very beginning that the IRS had at about that time a

14 discussion with him about engaging in an installment agreement and that the IRS may (emphasis

added) file a lien and when questioned about it the IRS agent stated it would be against your 16

property There was no information that a lien was filed would be filed or was going to be filed 17

This is supported by the fact that the installment agreement Holeman had with the IRS did not 18

19 indicate on its official form that a lien was filed or was to be filed Holeman did not (emphasis

added) make a conscious decision not to disclose those liens on Form U4 precisely because he

21

was not aware or advised of any such filings would be done or had been done It is indisputable 22

that there is no evidence that Holeman was made aware of the liens in 2009 or thereafter and 23

24 there is no evidence proffered that he received notice of the liens filed by the IRS Upon inquiry

26

27

2 Id Pages 3-14 28

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by FINRA District Stafftelephonically by Mr Michael Gerena Examination Manager and

Kathleen Halloran Principal Examiner of FINRAs District Staff raising questions about a

number of items that they had received as reported by a vendor (identified as LexisNexis)

including certain IRS liens Holeman denied knowledge of these items and some were proven to

be false and inaccurate In any event Holeman did not admit nor state that he was on notice of or

aware of any IRS liens filed It should be noted that Mr Gerena and Ms Halloran are with the

Long Island FINRA District Staff and not with Enforcement as Enforcement contends In

addition the responses Holeman provided to FIN RA s District Staff did not include any

admission of receiving notice or being aware of any IRS liens being filed

Holeman did immediately disclose to his employer David Lerner Associates Inc (DLA)

the information relating to the IRS liens that FINRA District Staff had contacted him about but i

conferring with private counsel did not report the information on Form U43 This action was no

in lieu of Holemans reporting obligations but rather to meet the stated purpose of the standard

of the Rule that Holemans primary regulator and employer be promptly and fully informed of

the facts relating to such disclosure It was never Holeman s position that the liens are material

as to him but that since they were reported there was no issue as to materiality There is no lying

or misrepresentation as to the facts on this issue except as misstated and misapplied by

Enforcement As previously stated in the record Holeman is not a licensed registered

representative authorized to solicit clients or make investment recommendations as he does not

hold State securities licenses Holeman has no clients no customers has no contact with the

3 See Wexler Letter

3

investing public and is not compensated by any commission or fee arrangement What

2 Enforcement refers to as self-serving and dubious arguments by Holeman are not (emphasis

3

added) in conflict with the evidence in the record and are factual and truthful The true facts in 4

this case have been ignored and given no weight 5

II FORM U4 FILINGS 6

7 Holeman immediately sought the advice of an attorney upon the initial contact by

8 FINRAs District Staff and after making the disclosure to DLA The Form U4 filings submitted

9

by Oppenheimer while Holeman was employed there were not shown to him and were not 10

signed by him as Enforcement incorrectly states Oppenheimer did not provide any copies of 11

these Form U4s to Holeman and Enforcement did not produce copies of such Form U4s signed 12

13 by Holeman as evidence because they do not exist bearing a signature they are not signed or

14 known to Holeman when they were filed by Oppenheimer As previously stated in the record

15

these Oppenheimer filings were administrative and did not require the employees signature or 16

knowledge that they were being filed4 Holeman on November 6 2013 uponjoining DLA 17

permitted his employer to conduct a background check and investigation which included credit 18

19 reporting agencies DLA did not report to Holeman any indication of any IRS liens that would

20 need to be addressed Holeman submitted two Form U4s one on November 7 2013 and one on

21

September 15 2014 prior to contact by FINRA and did not disclose any IRS tax liens because 22

he was not aware and had not received notice from the IRS that any such liens had been filed A 23

Form U4 filing was submitted on December 14 2014 without such disclosure because Holeman 24

25

26

27

4 Id at Page8 28

15

was not in receipt of any IRS tax lien notice and was responding to FINRAs inquiry on their

2 request see Holemans Response to Rule 8210 Request dated December 17 20145 Holeman

3

did file a Form U4 amendment reporting the IRS liens on April 8 2015 after working with his 4

private attorney and in-house counsel at DLA which had supported the position of not filing up 5

6 to that date evidenced by the email response to Mr Gerena noted on Respondents Opening

Brief dated August 15 20186 There were amendments to that filing due to inadvertent errors an

8 to correctly indicate the date when Holeman saw for the first time copies of the IRS liens at the

9

Monmouth County Clerks Office IO

III THE ANNUAL COMPLIANCE QUESTIONNAIRE 11

As described in Respondents Opening Brief filed with the SEC the completed 12

13 DLA questionnaire was reviewed and disclosed at that time with DLA Management in keeping

14 with the position taken based on private counsel and with DLA Management that the response to

the relevant questions was no 7 Consequently the information relating to the IRS liens had 16

been provided to DLA and as such the questionnaires completion was not in violation of FIN 17

Rule 2010 Specifically Holeman did not fail to disclose information to his firm and did not 18

19 violate FINRA Rule 2010

20 IV ENFORCEMENTS INACURATE AND MISLEADING STATEMENTS

21

It is Enforcement that is disingenuous in their characterization of Holemans arguments 22

and explanations labeling them as tortured and shocking and attacking his position as CCO 23

24

25

26 s See Certified Record Index -CX-24 6 ld Page6

27 1 Respondents Opening Brief in Support of the Application for Review of Disciplinary Action Taken by FINRAfiled with the SEC August 15 2018 1

28

impugning his outstanding record in the financial services industry including his tenure as a five

2 year member of the Chicago Board Options Exchange Business Conduct Committee and as

3

President of the Compliance and Legal Division of SIFMA ( fka Securities Industry 4

5 Association) Holeman has worked with many senior officials of regulatory bodies and has

6 never had his integrity and honesty challenged or questioned It is inappropriate and unbecoming

7 a lawyer and a FINRA Enforcement officer to describe an argument or defensive position taken

8 by the Respondent as comically and points to their attempt to discredit Holeman 8 There is

9

nothing comical concerning this matter and its very serious potential consequences IO

11 Enforcement presented evidence about the IRS being required to notify taxpayers within five

12 business days after a federal tax lien is filed and based their argument on a study that sampled

13 125 taxpayers out of approximately 948000 lien notices sent by the IRS9 Enforcement and the

14 NAC also cited the mailbox rule but has no evidence that Holeman had in fact received any

15

lien notices from the IRS The references to Holemans statements regarding the IRS liens are 16

17 purposely taken out of context by Enforcement and at no time do any of those statements by

18 Holeman refer to the IRS liens having been received or being aware that they had been filed or

19 would be filed The fact that Holeman was advised that any IRS liens that may be filed would be

20 against property and repeated that understanding in his responses to FINRA does not equate that

21

Holeman had received any IRS tax lien notices or that he was aware of their filing Holeman did 22

23 not allow the IRS to provide to Enforcement documentation of certified mailing to him He did

24 so himself on the advice of counsel as such permission to Enforcement was not considered

25

26

27 8 FINRA s Opposition to Applicationor Review dated September 17 2018 Page 9footnote 3

28

9 Hearing Transcript dated January 19 2017 (Bates 000197) Pages 129-131

required Holeman received a response from the IRS and provided it to his attorney10

2 Enforcement again refers to Holemans Decmber 2014 letter stating where he appeared to

3

acknowledge existence of the liens which is not true or correct11 Moreover Enforcement 4

continues to state that questions had been raised but provided no evidence and no copies of 5

6 the very liens that they were referring to 12 In Au a former IRS attorney is quoted as follows

7 When the attorney asked about the Notice sent to Au the IRS contact told her that it (the IRS)

8 does not retain copies of these notices13 Au insisted that he never received the Notice and

9

because he did not know the IRS filed the lien he did not commit a willful violation by failing to IO

amend his Form U4 to disclose the lien the Hearing Panels decision dismissed the complaint by 11

Enforcement14 Enforcement repeatedly cites Holemans long standing employment in the 12

13 financial services industry particularly as a Chief Compliance Officer in a derogatory manner

14 seeking to imply a level of knowledge and experience that would reside with a person in this

15

position This matter does not rest on the long experience of the Respondent and has no 16

connection to that experience 17

V ARGUMENTS18

19 Enforcement would have Holemans defenses and arguments dismissed without merit or

20 consideration and they should not be Enforcement repeats its faulty position based on no

21

evidence and inconclusive arguments Please see Respondents Opening Brief filed with the 22

23

24

25 10 Id Pages 208209 11 FINRA s Opposition to Application for Review dated September I 7 20 I 8 Page 9

26 12 Id Page 9 10 13 In re Au Hearing Panel decision - Department of Enforcement vs Vincent Au - December I 2

27 2016- Disciplinary Proceeding No 20303665330 14 Id

28

24

18 Id

SEC dated August 15 2018 that lists at pages 11 through 13 which details the NACs wrongful

2 conclusions 15 It is clear that Holeman relied on private counsel from the beginning of this

3

inquiry and used the language provided by his private attorney in the language used in the initial 4

Form U4 filing as described in the Wexler Letter 16 In addition it is clear that Holeman made 5

full disclosure to his firm as is evidenced by the email from the General Counsel to FINRA 6

7 which the NAC and Enforcement seek to disallow 17 And the Wexler Letter also shows that

8 Holeman sought to obtain advice on the matter from the start of this inquiry Moreover

9

Enforcement wishes to discount affidavits by DLAs General Counsel and President that 10

acknowledges they were informed about the IRS liens by Holeman and did not require Holeman 11

to file a Form U4 amendment to report information on the IRS liens They represent an importan 12

13 part of Holemans defense and should be given proper weight 18 With respect to the Form U4

14 filings by Oppenheimer Enforcements position makes no sense since Holeman was not aware

15

of their filings and therefore could not make sure the form is accurate And there is no ample 16

contrary evidence that supports Enforcements position There was no signature affixed to those 17

filings and no acknowledgment or consent to their filing by Holeman FINRA District Staff did 18

19 not provide copies of the liens as filed even though their witness stated that she spoke with an

20 investigator who went to the Monmouth County I9 Implying that there was a visit by FINRA

21

District Staff 22

23

15 Respondents Opening Brief in Support of the Applicationor Review of Disciplinary Action 25 Taken by FINRAfiled with the SEC August 15 2018 Pages 11-13

16 see W exer Letter 26 11Respondents Opening Brief in Support of the Applicationor Review of Disciplinary Action

Taken by FJNRA filed with the SEC August 15 2018 Page 6 Page IO

19 Hearing Transcript dated January 19 2017 (Bates 000197) Pages77 78 8

27

28

15

16

17

23

25

to the Monmouth County Clerks office and they did not obtain a copy of the liens that had

2 been filed there FINRA District staffs initially sent Holeman a chart listing sketchy

3

information about a number of items that included the IRS liens and other information that were 4

proven to be false Holeman is pro se and does not have the army of lawyers and paralegals that 5

comprise Enforcements staff to provide all of the citations and relevant decisions in this matter 6

7 but that situation should not serve to undermine the arguments that have and are being made as

8 reflected in the record Holemans actions were not willful as he made the disclosures to his

9

employer and relied on the advice of counsel especially in connection question 14M in the Form IO

U4 The NACs sanctions are oppressive excessive and not in keeping with the FINRAs 11

Sanctions Guidelines In light of the mitigating circumstances involving this matter the reliance 12

13 on the advice of private counsel and disclosure made to Holemans employer among other

14 reasons such as no harm to the investing public and no aggravating factors the NACs actions

are wholly inappropriate Enforcement also seeks a denial ofHolemans request for oral

arguments inexcusably stating because the issues have been thoroughly briefed and can be

adequately determined on the basis of the record20 Precisely because Holeman has challenged 18

19 the misstatements and inaccurate representations by Enforcement concerning the record and

20 because the decisional process would be significantly enhanced by personal appearance to

21

observe credibility demeanor character and veracity oral arguments are respectfully requested 22

and should be granted

26

27

20FJNRA s Opposition to Applicationor Review dated September 17 2018 Page 19footnote 6 28

9

24

VI CONCLUSION

2

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4

5

Enforcement has manipulated the content of the testimony and record to fit their

narrative Enforcement failed to meet the standard of a preponderance of evidence to support

their charges The truth especially on complex issues should not be decided quickly The stakes

6 are high with the potential consequences attached to the sanctions that may be imposed on

7 Holeman who at age seventy would be faced with a possible career ending situation in the

8

9

10

11

financial services industry Enforcements mere repetitions and assertions of their opinions and

beliefs is not a way to the truth Enforcement has speculated on this matter leading them to mak

assumptions For those reasons oral arguments and a personal appearance before the

12 Commission is requested and should be granted Based on the above and the entirety of this

13 Brief the Commission should vacate the finding and sanctions imposed by the NAC on Holem

14

15

16

17

or permit and schedule a personal appearance at the Commissions discretion before a decision is

reached

Dated September 28 2018

18

19 Allen Holeman prose

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28 10

CERTIFICATE OF SERVICE

I hereby certify that on September 28 2018 I caused an original and copies of the

foregoing

Respondents Answer to FINRAs Brief in Opposition to the Appellants Application for

Review of Disciplinary Action Taken by FINRA

SEC Administrative Proceeding No 3-18546-

ADJUDICATORY COUNCILS DECISION Plaintiff vs ALLEN HOLEMAN Defendant

be sent by FedEx Express Mail and US Postal Service mail addressed as follows

An original and three copies to

Brent J Fields Secretary

The Office of the Secretary

Securities and Exchange Commission

100 F Street NE

Room 10915

Washington DC 20549-1090

And a copy to

FINRA

Office of the General Counsel

Attn Colleen Durbin

Associate General Counsel

1735 K Street NW

Washington DC 20006

CO David Lerner Associates Inc

4 77 Jericho Turnpike

Syosset NY 11791-9006

516-390-5573

TABLE OF CONTENTS

I RESPONDENTS ANSWER TO FINRA BRIEF IN OPPOSITION TO THE APPELLANTS APPLICATION FOR REVIEW OF DISCIPLINARY ACTION TAKEN BY FINRA 1

II F O RM U 4 FI LIN GS 4 5

III THE ANNUAL COMPLIANCE QUESTIONNAIRE S

IV ENFORCEMENTS INACCURATE AND MISLEADING ST A TE M E NTS 5 6 7

V ARGUMENTS 789

VI CONCLUSION 910


Case



Other Authorities



2018 125 8



2018 679


2017 610

ii

16

17

20

2 BEFORE THE


4 WASHINGTON DC

5

6

7


8 PLAINTIFF

9 vs

10

11

ALLEN HOLEMAN

SYOSSET NY


12 RESPONDENT

13 COMPLAINT NO 2014043001601

14 DATED MAY212018

15



I INTRODUCTION19


21

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23



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28


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2 Id Pages 3-14 28

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3 See Wexler Letter

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4 Id at Page8 28

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27 1 Respondents Opening Brief in Support of the Application for Review of Disciplinary Action Taken by FINRAfiled with the SEC August 15 2018 Page 11

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V ARGUMENTS18



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District Staff 22

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VI CONCLUSION

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reached


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28 10



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573


Case



Other Authorities



2018 125 8



2018 679


2017 610

ii

16

17

20

2 BEFORE THE


4 WASHINGTON DC

5

6

7


8 PLAINTIFF

9 vs

10

11

ALLEN HOLEMAN

SYOSSET NY


12 RESPONDENT

13 COMPLAINT NO 2014043001601

14 DATED MAY212018

15



I INTRODUCTION19


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VI CONCLUSION

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reached


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foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573

16

17

20

2 BEFORE THE


4 WASHINGTON DC

5

6

7


8 PLAINTIFF

9 vs

10

11

ALLEN HOLEMAN

SYOSSET NY


12 RESPONDENT

13 COMPLAINT NO 2014043001601

14 DATED MAY212018

15



I INTRODUCTION19


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VI CONCLUSION

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reached


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25

26

27

28 10



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573

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VI CONCLUSION

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reached


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25

26

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28 10



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573

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District Staff 22

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Taken by FJNRA filed with the SEC August 15 2018 Page IO


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VI CONCLUSION

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reached


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25

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27

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foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573



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VI CONCLUSION

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reached


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28 10



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573

15



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VI CONCLUSION

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reached


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foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573



3






9






15






21




25

26

27 8 FINRA s Opposition to Applicationor Review dated September 17 2018 footnote 3

28




3






9






15



V ARGUMENTS18



21


23

24




28

24

18 Id



3






9






15






21

District Staff 22

23





27

28

15

16

17

23

25



3






9











21



26

27


9

24

VI CONCLUSION

2

3

4

5






8

9

10

11






14

15

16

17


reached


18


20

21

22

23

24

25

26

27

28 10



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573



3






9






15



V ARGUMENTS18



21


23

24




28

24

18 Id



3






9






15






21

District Staff 22

23





27

28

15

16

17

23

25



3






9











21



26

27


9

24

VI CONCLUSION

2

3

4

5






8

9

10

11






14

15

16

17


reached


18


20

21

22

23

24

25

26

27

28 10



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573

24

18 Id



3






9






15






21

District Staff 22

23





27

28

15

16

17

23

25



3






9











21



26

27


9

24

VI CONCLUSION

2

3

4

5






8

9

10

11






14

15

16

17


reached


18


20

21

22

23

24

25

26

27

28 10



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573

15

16

17

23

25



3






9











21



26

27


9

24

VI CONCLUSION

2

3

4

5






8

9

10

11






14

15

16

17


reached


18


20

21

22

23

24

25

26

27

28 10



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573

VI CONCLUSION

2

3

4

5






8

9

10

11






14

15

16

17


reached


18


20

21

22

23

24

25

26

27

28 10



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573



foregoing










100 F Street NE

Room 10915


And a copy to

FINRA


Attn Colleen Durbin


1735 K Street NW

Washington DC 20006




516-390-5573

received oct 01 2qw...as to him, but that since they were reported there was no issue as to...

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